1 See Institute Memoranda to Tax Committee No. 13-96, Operations Committee No. 8-96 and Transfer Agent Advisory Committee No. 23-96, dated April 30, 1996, and to Tax Members No. 19-96,
Operations Members No. 18-96 and Transfer Agent Advisory Committee No. 22-96, dated April 25, 1996.
July 16, 1996
TO: OPERATIONS COMMITTEE No. 13-96
TAX COMMITTEE No. 25-96
TRANSFER AGENT ADVISORY COMMITTEE No. 41-96
ATTENDEES AT MAY 15 MEETING
RE: DRAFT LETTER ON NONRESIDENT ALIEN WITHHOLDING REGULATIONS
______________________________________________________________________________
As we previously informed you, the Internal Revenue Service ("IRS") has requested that
comments on the recently proposed regulations regarding withholding tax on payments to
nonresident alien investors be submitted by July 22, 1996.1 The attached draft Institute
comment letter focuses primarily on the need to expand the definition of "U.S. established
financial market" -- which would be the new standard for obtaining treaty benefits without an
IRS-generated taxpayer identification number -- to cover shares of mutual funds regulated
under the Investment Company Act of 1940. The letter also urges a number of other
modifications which were discussed at the May 15, 1996 members meeting and a May 29, 1996
Institute/IRS meeting on the proposed regulations.
Please provide any comments you may have on the draft letter to the undersigned at
202-326-5832 by Thursday, July 18. We will keep you informed of developments.
Keith D. Lawson
Associate Counsel - Tax
Attachment